Privacy Policy

1. Introduction

Welcome to Tunanuki (“we,” “our,” or “us”). Tunanuki is a web application designed to help users learn Japanese through shadowing - a language acquisition technique involving listening and repeating spoken content.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our application. Please read this policy carefully. If you disagree with its terms, please discontinue use of the application.

This policy is intended to comply with applicable privacy laws and regulations, including the General Data Protection Regulation (GDPR) for users in the European Union and European Economic Area, and applicable U.S. state privacy laws.

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

• Email address (used to identify your account and communicate with you)
• Name or display name (used to personalize your experience)
• Password (stored in hashed, non-reversible form)

2.2 Usage and Analytics Data

We automatically collect certain information about how you use Tunanuki, including:

• Features used, pages visited, and actions taken within the application
• Frequency and duration of use
• Progress and performance data related to shadowing exercises
• Device type, browser type, operating system, and language settings
• IP address and approximate geographic location (country/region level)
• Referring URLs and session identifiers

This data is used to improve the application, understand how users interact with our features, and provide a better learning experience.

2.3 Information We Do Not Collect

We do not collect audio recordings from your device. Shadowing exercises are processed locally in your browser, and voice input (if any) is not transmitted to our servers.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To create and manage your account
• To provide, operate, and improve Tunanuki's features
• To personalize your learning experience and track your progress
• To send you transactional emails (e.g., account verification, password resets)
• To send product updates or announcements (you may opt out at any time)
• To analyze usage trends and improve the application
• To detect, prevent, and respond to technical issues or abuse
• To comply with our legal obligations

4. Legal Bases for Processing (GDPR - EU/EEA Users)

If you are located in the European Union or European Economic Area, we process your personal data under the following legal bases:

• Performance of a contract: Processing necessary to provide the Tunanuki service you have requested.
• Legitimate interests: Processing for analytics and service improvement, provided it does not override your rights and interests.
• Consent: Where we send you optional marketing communications, we rely on your consent, which you may withdraw at any time.
• Legal obligation: Processing required to comply with applicable law.

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

5.1 Service Providers

We may share data with trusted third-party service providers who assist us in operating Tunanuki (e.g., hosting providers, analytics providers, email service providers). These providers are contractually obligated to handle your data securely and only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or in response to a valid request by a public authority (e.g., a government agency or law enforcement).

5.3 Business Transfers

If Tunanuki is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice in the application before your data is transferred and becomes subject to a different privacy policy.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide you with our services. You may request deletion of your account and associated data at any time (see Section 8).

Analytics data may be retained in aggregated, anonymized form for longer periods for statistical analysis and product improvement.

7. International Data Transfers

Tunanuki serves users globally, including in the European Union and the United States. If you are located in the EU/EEA, your personal data may be transferred to and processed in countries outside the EU/EEA, including the United States, which may not offer the same level of data protection as your home country.

When we transfer personal data outside the EU/EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or we rely on adequacy decisions where applicable.

8. Your Rights and Choices

8.1 All Users

Regardless of your location, you may:

• Update or correct your account information at any time through your account settings
• Opt out of marketing emails by clicking “unsubscribe” in any email we send
• Request deletion of your account by contacting us at the address below

8.2 EU/EEA Users (GDPR Rights)

If you are located in the EU/EEA, you have the following additional rights:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data (“right to be forgotten”)
• Right to restriction: Request that we limit how we process your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time

To exercise any of these rights, please contact us at the address in Section 11. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection authority.

9. Children's Privacy

Tunanuki is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If you are under 13, please do not create an account or use the application.

If we become aware that we have inadvertently collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at the address in Section 11.

Users in the European Union must be at least 16 years of age to consent to data processing under the GDPR, unless the applicable member state law provides a lower age threshold (minimum 13).

10. Data Security

We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encrypted storage of passwords and secure HTTPS connections.

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

11. Cookies and Tracking Technologies

Tunanuki uses cookies and similar technologies (e.g., local storage, session tokens) to maintain your session, remember your preferences, and collect analytics data. You can control cookies through your browser settings; however, disabling certain cookies may affect the functionality of the application.

We do not use cookies for advertising or cross-site tracking.

12. Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or your personal data, please contact us at:

Tunanuki
Email: [your-contact-email@example.com]
Website: [your-website-url]

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this page and, where appropriate, by sending you an email notification. We encourage you to review this policy periodically.

Your continued use of Tunanuki after changes become effective constitutes your acceptance of the updated policy.